25% TARIFF PROPOSED ON IMPORTED ORTHOPEDIC PRODUCTS (Orthopedic This Week)
This week, the Office of the United States Trade Representative issued a notice that it intends to impose a new 25% tariff on a large number of medical devices and drugs, including orthopedic products imported from China.
The wording of the proposed rule is unambiguous. All “orthopedic or fracture appliances, and parts and accessories thereof and all artificial joints and parts and accessories, thereof” coming from China would be subject to this proposed 25% tariff.
While the U.S. is the largest supplier of orthopedic products around the world, U.S. based suppliers routinely use components which are manufactured in China.
At the just completed American Academy of Orthopaedics Surgeons (AAOS) annual meeting, for example, 38 Chinese origin companies had booths—the most from a country outside the U.S.
They were selling to both the attending physicians AND to other exhibiting companies.
The notice sets in motion a period of public commentary. All written comments are due May 15, 2008. The due date for post-hearing rebuttal comments is May 22, 2018.
Then, if nothing changes, orthopedic products and components and a long list of medical devices (MRIs, CTs, syringes, catheters, for example) and their components coming from China will become more expensive.
Will China retaliate?
And if it does, will the fact that a significant portion of orthopedic products are manufactured in Indiana, the home of Vice President Mike Pence, make this industry particularly vulnerable?
We will stay on top of this and report on all public comment.
The following is a partial list of the medical devices, orthopedic products and other medical products which the U.S. government is proposing to tax.
| LIST OF ORTHOPEDIC MEDICAL DEVICES AND RELATED PRODUCTS SUBJECT TO 25% TARIFF | |
| 90181300 | Magnetic resonance imaging electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences |
| 90181400 | Scintigraphic electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences |
| 90181940 | Electro-diagnostic apparatus for functional exploratory examination, and parts and accessories thereof |
| 90181955 | Electro-diagnostic patient monitoring systems |
| 30032000 | Medicaments containing antibiotics, nesoi, not dosage form and not packaged for retail |
| 30021300 | Immunological products, unmixed, not put up in measured doses or in forms or packings for retail sale |
| 30021400 | Immunological products, mixed, not put up in measured doses or in forms or packings for retail sale |
| 30021500 | Immunological products, put up in measured doses or in forms or packings for retail sale |
| 30021900 | Blood fractions, nesoi |
| 30022000 | Vaccines for human medicine |
| 29242957 | Diethylaminoacetoxylidide (Lidocaine) |
| 90211000 | Orthopedic or fracture appliances, and parts and accessories thereof |
| 90189075 | Electro-medical instruments and appliances nesi, and parts and accessories thereof |
| 90189080 | Instruments and appliances used in medical, surgical, dental or veterinary sciences, nesi, and parts and accessories thereof |
| 90213100 | Artificial joints and parts and accessories thereof |
| 90111040 | Stereoscopic microscopes, provided with a means for photographing the image |
| 90111080 | Stereoscopic microscopes, other than those provided with a means for photographing the image |
| 90112040 | Microscopes for microphotography, microcinematography or microprojection, provided with a means for photographing the image |
| 90119000 | Parts and accessories for compound optical microscopes, including those for microphotography, microcinematography or microprojection |
| 90121000 | Microscopes other than optical microscopes; diffraction apparatus |
| 90129000 | Parts and accessories for microscopes other than optical microscopes, and for diffraction apparatus |
| 90181200 | Ultrasonic scanning electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences |
| 90181300 | Magnetic resonance imaging electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences |
| 90181400 | Scintigraphic electro-diagnostic apparatus used in medical, surgical, dental or veterinary sciences |
| 90181940 | Electro-diagnostic apparatus for functional exploratory examination, and parts and accessories thereof |
| 90181955 | Electro-diagnostic patient monitoring systems |
| 90181975 | Printed circuit assemblies for electro-diagnostic parameter acquisition modules |
| 90181995 | Electro-diagnostic apparatus nesi, and parts and accessories thereof nesi |
| 90182000 | Ultraviolet or infrared ray apparatus used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof |
| 90183100 | Syringes, with or without their needles; parts and accessories thereof |
| 90183200 | Tubular metal needles and needles for sutures, used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof |
| 90183900 | Catheters, cannulae and the like nesi, used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof |
| 90184100 | Dental drill engines, whether or not combined on a single base with other dental equipment, and parts and accessories thereof |
| 90184940 | Dental burs |
| 90184980 | Instruments and apparatus used in dental sciences, nesi, and parts and accessories thereof |
| 90189030 | Anesthetic instruments and appliances nesi, used in medical, surgical, dental or veterinary sciences, and parts and accessories thereof |
| 90189060 | Electro-surgical instruments and appliances nesi, other than extracorporeal shock wave lithotripters and parts and accessories thereof |
| 90189075 | Electro-medical instruments and appliances nesi, and parts and accessories thereof |
| 90189080 | Instruments and appliances used in medical, surgical, dental or veterinary sciences, nesi, and parts and accessories thereof |
| 90221200 | Computed tomography apparatus based on the use of X-rays |
| 90221300 | Apparatus based on the use of X-rays for dental uses (other than computed tomography apparatus) |
| 90221400 | Apparatus based on the use of X-rays for medical, surgical or veterinary uses (other than computed tomography apparatus) |
| 90221900 | Apparatus based on the use of X-rays other than for medical, surgical, dental or veterinary use |
| 90222100 | Apparatus based on the use of alpha, beta or gamma radiations, for medical, surgical, dental or veterinary use |
| 90222980 | Apparatus based on the use of alpha, beta or gamma radiations, other than for medical, surgical, dental or veterinary use, nesi |
| 90223000 | X-ray tubes |
| 90229005 | Radiation generator units |
| 90229015 | Radiation beam delivery units |
| 90229025 | X-ray generators, high tension generators, desks, screens, examination or treatment tables, chairs and similar apparatus, nesi |
| 90229040 | Parts and accessories of X-ray tubes |
| 90229060 | Parts and accessories of apparatus based on the use of X-rays |
| 90229095 | Parts and accessories of apparatus based on the use of alpha, beta or gamma radiations |
| 90251120 | Clinical thermometers, liquid-filled, for direct reading, not combined with other instruments |
| 90261020 | Electrical instruments and apparatus for measuring or checking the flow or level of liquids |
| 90269020 | Parts and accessories of electrical instruments and apparatus for measuring or checking variables of liquids or gases |
| 90278025 | Nuclear magnetic resonance instruments |